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Add your name to these public comments to be submitted to Michigan state agencies by signing this petition.

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Last June, the preliminary Line 5 Alternatives Study was released, and more than 23,000 people submitted their comment calling for the shutdown of Line 5 as the only alternative that will truly protect the Great Lakes from an oil spill. The revised and final Alternatives Study has just been released, which has triggered a second comment period that is now open.

Prevent a Catastrophic Great Lakes Oil Spill

The deadline for public comments is December 19, 2017, so please sign on and submit your comment today via this online form. Let's prevent a devastating oil spill in the Straits of Mackinac.

I am writing to submit my official comment in response to the State of Michigan’s Line 5 final alternatives analysis dated October 26 and released on November 20. I am deeply disappointed in this final analysis. A draft alternatives report released in June was riddled with errors and omissions, and the final report contains most of the same failures.

This report fails to meet its overall purpose of “providing the State of Michigan and other interested parties with an independent, comprehensive analysis of alternatives to the existing Straits Pipelines, and the extent to which each alternative promotes the public health, safety, and welfare and protects the public trust resources of the Great Lakes.”

It lacks credibility because its author is Dynamic Risk, a firm with ties to Enbridge, the Canadian energy transport company that owns Line 5. Even worse, it absurdly underestimates the impact of a spill and ignores a viable alternative to Line 5 – use of existing infrastructure. An independent expert review in December 2015 documented the practicality of this alternative.

Decommissioning Line 5 in the Straits of Mackinac is the only alternative that will prevent an oil spill with catastrophic consequences for the Great Lakes and the State of Michigan. Moreover, this final alternative report affirms that decommissioning is a feasible option with zero risks to the Great Lakes and minimal economic impacts to Michigan customers (e.g., two cents more at the gas pump and roughly 10 to 25 cents more for propane in the Upper Peninsula).

It is time for the state to reject the flawed study, exercise its affirmative legal duty as public trustee of the Great Lakes and bottomlands, and shut down Line 5. The state should use that authority to revoke the 1953 easement agreement that Enbridge has consistently violated.

The risk of a spill is too great to allow Line 5 to continue to operate in the Great Lakes. Our state government should not put the Great Lakes, our economy, health, drinking water, fisheries, and way of life at risk from a catastrophic oil spill any longer. In fact, on November 16, the Coast Guard Coast commandant testified again to Congress that his agency is not prepared to clean up a large-scale pipeline oil spill in the Great Lakes.

I urge you to act as public trustees of our waters and bottomlands, enforce the easement in light of Enbridge’s ongoing violations, and begin the process of decommissioning Line 5 in the Straits of Mackinac to protect the Great Lakes from a catastrophic oil spill. The State of Michigan has a legal duty to take this enforcement action. Enbridge’s ongoing violations cannot be remedied. It is time for the state to act decisively and with urgency.

Specifically, the draft report on alternatives to Line 5 in the Mackinac Straits:

Fails to follow the recommendations and standards outlined in the Michigan Petroleum Pipeline Task Force Report, which resulted from a process created by the governor and co-chaired by the attorney general, and therefore cannot be used by the State of Michigan “in making decisions about the future of the Straits Pipelines.”

Neglects to provide the state with an independent, fair analysis of the alternatives to Line 5 as required by the Task Force Report. This final report remains biased toward allowing Line 5 to continue to operate and/or allowing Enbridge to build new oil infrastructure in the Straits of Mackinac and further expand its operations. That bias grows out of past, and potentially future, business relationships between Enbridge and the report’s authors.

Fails to analyze existing pipeline infrastructure as an alternative to Line 5 in the Straits, which the state required Dynamic Risk to analyze, and leaving it out conflicts with Task Force recommendation 3 (b). It is unacceptable that the contractor eliminated this alternative without any analysis. The 1953 easement granted with strict conditions by the state to Enbridge does not guarantee transport of 540,000 barrels per day (bpd) of oil and natural gas liquids. In fact, the 1953 MPSC Order states 300,000 bpd, which means Enbridge is currently operating Line 5 at 80 percent over design capacity.

Fails to analyze new evidence disclosed by Enbridge affecting the pipeline’s integrity, including external corrosion, 48 bare metal spots caused by the installation of screw anchors, compromised cathodic protection, and historic excessive pipeline spans greater than the 75-feet limit (including a 286-foot span that was unsupported for years), as required by the legal operating agreement with the State of Michigan. Dynamic Risk’s rationale, in part, is that "it would be inappropriate to speculate on any of the above aspects of the coating condition."

Fails to consider tribal sovereign treaty rights and feedback on the basis that Dynamic Risk was not a party to tribal and state consultations, which is an unacceptable dismissal of input by a key stakeholder.

Grossly underestimates the total economic spill costs at between $147 million and $310 million, when Enbridge’s cleanup costs of its 2010 Line 6B pipeline oil spill along a 40-mile stretch of the Kalamazoo River cost more than $1.2 billion.

Overestimates an impact to propane supply, greatly exceeding what independent experts have determined would be necessary to provide the Upper Peninsula’s Rapid River facility with an alternative supply. The flawed report finds that up to 35 railcars per week or 15 truckloads per day would be necessary, while another study found it would take only one railcar or 3 - 4 truckloads per day to replace the Line 5 propane supply to the U.P.

Continues to show an unfair bias towards building a tunneled pipeline in the Mackinac Straits. The report estimates a much lower cost for a tunnel than other estimates for this type of infrastructure; it fails to consider the risk of a spill to the Great Lakes, rivers and streams from other portions of the 64-year-old pipeline if the Straits portion were rebuilt. Dynamic Risk prefers new pipelines, which was evident when the firm aggressively promoted building a tunnel in its proposal to do this report, and its analysis is deeply flawed.

Please listen to “we the people” who want this pipeline shut down to protect our water, health, and way of life.

Tim Housley signed
2017-12-12 20:00:27 -0500

The major" Dilbit" disaster of 2010 in the Kalamazoo River would seem minor by comparison to a Macinac straits rupture should the outdated dilapidating pipeline do likewise. Please find an alternative.

Sara Cockrell signed
via Judy Childs2017-12-12 19:44:38 -0500

Line 5 has extended beyond its time limit & presents too much risk to Michigan natural resources & livelihoods, in addition to America’s greatest source of fresh water! SHUT IT DOWNNOW!!!

Mary Beth Champlin signed
2017-12-12 19:32:49 -0500

As a citizen of Michigan I urge our Governor Attorney General and all state regulatory and environmental protective agencies to shut down Line 5 and to stand with the people of the state and protect this most valued resource. Do not wait until we are in the Clean up Phase.Do it now.

John Gerty, Jr. signed
2017-12-12 19:22:09 -0500

Enbridge already provided Michigan with one massive oil spill in our Kalamazoo River. Their Line 5 Pipeline was built with an expected lifespan and they have gone way beyond this point. Enbridge has not been transparent about the condition of Line 5. There are several locations in the Straits where the pipe exceeds its unsupported free span; there are support structures which are tilted; thye have only recently admitted that protective coatings on several places are missing. We also have Enbridge’s recent admission that some parts of the pipe, where they can make the measurements, have lost 26% of its thickness. On top of this, we now have a behind-closed-doors deal with our Republican Governor. The parties offering assurances on this pipeline are all suspect. None of them have a good record of performance.

Jade Cruz signed
via Chase Gifford2017-12-12 19:15:18 -0500

Matt Warner signed
2017-12-12 18:59:33 -0500

Shutdown line 5

Penney Rydman signed
2017-12-12 18:51:19 -0500

Please. Do not sell out the real value you’re dealing with here. Assume this line will fail—and during your lifetime. What’s at stake is utterly irreparable, irreplaceable. It needs your protection. We need you to protect it. Please: Step. up.

Pamela Allard signed
via Katrina Anne2017-12-12 18:46:09 -0500

Mary Rapin signed
2017-12-12 18:02:47 -0500

I support the views and comments made by Oil & Water Don’t Mix and the Tip of the Mitt Water Shed Council and feel that the only responsible action is to decommission line 5.

Josephine Hendrix
posted about this
on Facebook2017-12-12 17:55:09 -0500

JOIN ME and tell the State of Michigan the only acceptable way to protect the Great Lakes is to SHUTDOWN LINE 5.

JOIN ME and tell the State of Michigan the only acceptable way to protect the Great Lakes is to SHUTDOWN LINE 5.

Judy Childs signed
via Lou Ann McKimmy2017-12-12 17:05:41 -0500

I am bitterly disappointed in Snyder’s acceptance of Enbridge’s “studies.” Just have that fox protect the hen house, boys. Snyder is obviously in for this for his own personal gain. The Great Lakes get wonderful lip service by Republicans, but like everything else the Republican Party is doing now, they are only for themselves. This 64 year old pipeline originally slated to last 50 years is in need of immediate shutdown. Period. Piping oil from Canada to Canada with huge personal risk is not good for Michigan.

Melissa Culver signed
via Lou Ann McKimmy2017-12-12 17:00:46 -0500

Our Great Lake is worth more then the money we won’t receive (and who REALLYRECEIVESTHATMONEY??) from Enbridge. Our Governor will be gone from office..termed out..so for some reason (which I suspect has everything to do with his reward at the expense of Michigan) he has chosen to protect Enbridge interest instead of Michigan’s interest. It’s wrong…he should shut down Line 5 now!

Lou Ann McKimmy
posted about this
on Facebook2017-12-12 16:34:55 -0500

JOIN ME and tell the State of Michigan the only acceptable way to protect the Great Lakes is to SHUTDOWN LINE 5.

Lou Ann McKimmy signed
2017-12-12 16:34:45 -0500

Line 5 is a disaster waiting to happen.

Beth Marcott signed
2017-12-12 16:22:55 -0500

Please shut line 5 down now. We have wind and solar and don’t need the out dated fossil fuel energy.

Paula Miller signed
2017-12-12 16:21:47 -0500

Oil and Water Don’t mix! No to line 5!

Alison Paton signed
2017-12-12 16:01:17 -0500

Shut it down NOW before it is too late!!!!

Thomas Gerou signed
via Peggy Gerou2017-12-12 15:53:44 -0500

David Ermisch signed
2017-12-12 15:44:38 -0500

Pipeline spills continually occur, causing devastating damage to the environment. Since 1986 over 9,000 pipeline breaks have leaked over 4 million barrels of oil. Michigan has already suffered from oil contamination in the Kalamazoo River.

Barbara Fisher signed
via Marta Olson2017-12-12 15:25:08 -0500

Please shut down Line 5 and continue studying the effects of a break on our great lakes – the thoughts of a leak are overwhelming. Please consider all those on the lakes and that depend on the lakes for survival. Can;t survive on lakes full of oil.

Deb Hughes signed
2017-12-12 14:58:34 -0500

Take down line 5 now!! No more bad Energy!

Time for good decision making for our state!

Amber Bowen signed
2017-12-12 14:51:27 -0500

Amber Bowen

Bette Donahue signed
2017-12-12 14:34:11 -0500

These great lakes aren’t called “great” without reason. They are the lifeline for drinking water, food, and the very economy that keeps Michigan prospering. WHAT, exactly, is plan B should this precious lake die under our watch? What happens to a body of fresh water this size when it becomes unavailable for drinking, fishing, swimming and recreational activities?

PLEASE close down line 5 before we are faced with these dire consequences.

Edith Gerber signed
2017-12-12 14:23:07 -0500

Please protect our most valuable resource….WATER!

Leonard Page signed
2017-12-12 14:01:04 -0500

COMMENTS OF LEONARDPAGE

MEMBER OF SACCPJEPUBLICCOMMENTHEARING, DECEMBER 12, 2017

ON DYNAMICRISKFINALREPORT

LITTLEBEARARENA, ST. IGNACE, MICHIGAN

I WISH TO THANKTHEPROFESSIONALSTAFF OF THEVARIOUSSTATEAGENCIESANDTHEMEMBERS OF THEPSABFORTHEIRSERVICE. YOUHAVESPENTMANYHOURS ON THISLINE 5 ISSUE. HOWEVER, WE SHARETHEFRUSTRATION AT THELACK OF PROGRESSANDTHESADFACTTHATANYPSABRECOMMENDATIONS – NOWPUSHEDBACKUNTILLATENEXTYEAR – AREPROBABLYDESTINED TO BE IGNORED.

WE HADHOPEDTHATTHEWIDESPREADANDDETAILEDCRITIQUE OF JUNEDRAFTWOULDCAUSEDYNAMICRISK TO CORRECTITSMANYDEFICIENCIES. INSTEAD, DYNAMICCHOSE TO SIMPLYRESTATEITSCONCLUSIONS, BUTWITHEVENHIGHERLEVELS OF ENGINEERINGJARGON AS ITSSMOKESCREEN.DYNAMICRISKHASUTTERLYFAILEDITSPROMISE TO DO A COMPLETE, INDEPENDENTANDBALANCEDREPORT ON THELINE 5 ALTERNATIVES. DESPITETHECLEARLANGUAGE OF STATE’S RFP, DYNAMICELECTEDNOT TO DO A THOROUGHSTUDY OF EITHERALTERNATIVE 2 (USINGTHEEXISTINGPIPELINEINFRASTRUCTUREANDALTERNATIVE 1 (CONSTRUCTING A NORTHERNROUTEPIPELINETHROUGHONTARIO). DESPITEHAVINGTHISCLEARCONTRACTUALVIOLATIONBROUGHT TO THEIRATTENTION, DYNAMICSTILLHASREFUSED TO COMPLETEITSAGREED-UPONASSIGNMENT.

I ALSOURGEYOUANDEACHMEMBER OF THEPSAB TO CAREFULLYREVIEW DR. ED TIMM’S RECENTLY (12/11/17) RELEASEDFINALTECHNICALPAPER ON THEBIASANDERRORS IN DYNAMIC RISK’S WORKHERE. WHILETHIS IS PRIMARILY AN ENGINEERINGDEBATE, EVENNON-ENGINEERSCANSEETHEPROBLEMSOUTLINED BY DR. TIMM. I SUBMIT TIMM’S PAPERPROVESTHEPOINTTHATTHESTATEMADE A GRAVEERROR IN ASKING AN OILINDUSTRYSUBCONTRACTOR TO DO AN INDEPENDENTANALYSIS. DYNAMICRISKWILLNOTRESPOND TO TIMMUNLESSYOUMAKETHEM. MAKETHEM! BETTERYET, ASKTHEMEADOWSRISKSTUDYGROUP TO DO A PEERREVIEW OF THEFINALREPORTAND DR. ED TIMM’S RESPONSE.ONEEXAMPLETHATTHETIMMREBUTTALHIGHLIGHTS IS THEDAMAGEDONE TO THETWINPIPELINESFROM 1953 TO 2003 AS REVEALED IN THEKIEFNERREPORT. WE KNOWTHAT IN 2003, INSPECTIONSSHOWED 16 UNSUPPORTEDSPANSGREATERTHAN 14O FEET, INCLUDINGONE AT ALMOST 300 FEET. THESEEASEMENTSPANVIOLATIONSSHOWTHEFUNDAMENTALDESIGNERROR IN PLACINGTHEPIPELINE ON THEBOTTOM OF THESTRAITSWITH AN ERRONEOUSASSUMPTION ON THEPOTENTIALIMPACT OF HIGHCURRENTS. BOTHDYNAMICRISKREPORTSCHOSE TO PASS ON THEDAMAGEATTRIBUTABLE TO THESEEASEMENTVIOLATIONS – CLAIMINGTHATONEINLINEINSPECTION IN 2014 SHOULDQUIETANYCONCERNS. DYNAMICRISKSHOULD BE EMBARRASSED TO ARGUETHAT A TESTFORCRACKSWOULDHAVEDISCLOSEDOTHERSTRUCTURALPROBLEMSATTRIBUTABLE TO 50 YEARS OF NEGLECT.THISRESULT- ORIENTEDCONCLUSIONSHOWS A DEGREE OF BIASANDFLAWEDANALYSISTHATDEFIESCOMMONSENSE—AND IS ALLTOOTYPICAL OF THISREPORT. DR. TIMM’S RESPONSE TO THE 2014 ILITESTWHITEWASH (PAGES 16-20) IS SIMPLYDEVASTATING TO DYNAMIC RISK’S ALLEGEDEXPERTISE. MOREIMPORTANTLY, IT IS YETANOTHERWARNINGSIREN TO ANYONETRULYINTERESTED IN KEEPINGOILOUT OF THEGREATLAKES.

THECRITICISMRAISED BY DR. TIMMPAPERSHOULDNOT BE FILEDAWAYLIKETHE PSAB’S 2018 REPORT. THEWORSTTHINGTHATTHEPSABCAN DO IS TO ACCEPT AN INCOMPLETEANDTECHNICALLYFLAWEDFINALREPORTFROMDYNAMICRISK. IT’S BADENOUGHKNOWINGTHE PSAB’S EFFORTSMAY BE IGNORED. DON’T MAKETHESITUATIONWORSE BY LEAVING A TERRIBLYFLAWEDFINALREPORT AS THE PSAB’S ONLYLEGACY.

LEONARDPAGE

9482 PAGEROAD

CHEBOYGAN, MI 49721

age

Judith Brock signed
2017-12-12 13:59:14 -0500

It is imperative to SHUTDOWNLINE 5. Common sense, scientific findings, studies of the pipeline, how damaged/old it is, how vulnerable our Great Lakes and connecting waterways are should there be ANY spill. This will be devastating to our fresh water supply, our economy, our tourism, many folks earning a living. IT IS THERIGHTTHING TO DO: Shut it down, NOW. Before it is too late and we will all suffer and be sorry. Waiting for ANOTHERFLINTWATERCRISIS? That one is unforgiveable for everyone involved.